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1There is no evidence in the record that 

Respondent had distributed phenylpropanolamine. 

2According to the affidavit of Mr. Douglas A. 

Snyder, a Drug Science Officer within the Drug and 

Chemical Evaluation Section in the Office of 

Diversion Control, under the Food, Drug and 

Cosmetic Act’s provisions pertaining to over-thecounter (OTC) products, ephedrine is lawfully 

marketed as a bronchodilator used to treat asthma. 

Govt. Exh. 27, at 3–4. Pseudoephedrine is lawfully 

marketed under the Food, Drug and Cosmetic Act’s 

OTC provisions as a decongestant. See id. at 4. 

3 In response to the methamphetamine epidemic, 

many States have enacted legislation making 

pseudoephedrine a Schedule V drug under State 

controlled substances acts. 

4According to the Suspicious Order Task Force, 

as of 1998 the cost to clean up a small boxed lab 

site was $30,000. See Gov. Exh. 28, at 18. 

DEPARTMENT OF JUSTICE 

Drug Enforcement Administration 

[Docket No. 04–16] 

T. Young Associates, Inc.; Revocation 

of Registration; Introduction and 

Procedural History 

On December 17, 2003, the Deputy 

Assistant Administrator, Office of 

Diversion Control, Drug Enforcement 

Administration, issued an Order to 

Show Cause to T. Young Associates of 

Hermitage, Tennessee (Respondent). 

The Show Cause Order proposed to 

revoke Respondent’s DEA Certificate of 

Registration, 004395TSY, as a 

distributor of List I chemicals, and to 

deny any pending applications for 

renewal or modification of the 

registration, on the ground that 

Respondent’s registration is inconsistent 

with the public interest as that term is 

defined in 21 U.S.C. § 823(h). See 21 

U.S.C. § 824(a)(4). 

The Show Cause Order alleged in 

substance that on July 31, 2001, 

Respondent applied for a modification 

of its registration as a List I chemical 

distributor requesting registration to 

handle and distribute 

phenylpropanolamine, ephedrine and 

pseudoephedrine at a new location. See 

Show Cause Order at 2. The Show 

Cause Order further alleged that 

Respondent sells primarily ‘‘gray market 

products’’ to convenience stores and gas 

stations, that Respondent’s owner had 

informed DEA Diversion Investigators 

(DIs) that List I chemical products 

amounted to approximately nine 

percent of his total sales, and that some 

of the manufacturers of the products 

sold by Respondent have received 

warning letters from DEA because the 

products were found during law 

enforcement seizures of clandestine 

laboratories. See id. The Show Cause 

Order further alleged that Tennessee led 

DEA’s southeast region in the number of 

illicit methamphetamine laboratory 

seizures, that most illegal 

methamphetamine is produced locally, 

and that methamphetamine production 

continues unabated. See id. at 2–3. 

The Show Cause Order further alleged 

that DEA had engaged an expert in the 

field of retail marketing and statistics 

who had studied the purchases of List 

I chemical products by hundreds of 

Tennessee retailers and concluded that 

these stores were purchasing these 

products in amounts that were far in 

excess of legitimate demand. See id. at 

4. The Show Cause Order alleged that 

small illicit laboratories procure the 

precursor chemicals required to 

manufacture methamphetamine from 

non-traditional retailers such as gas 

stations and small retail markets and 

that some of these retailers use multiple 

distributors to mask their acquisition of 

large amounts of listed chemicals. See 

id. 

Respondent, through its counsel, 

requested a hearing. The matter was 

assigned to Administrative Law Judge 

(ALJ) Mary Ellen Bittner, who 

conducted a hearing in Nashville, 

Tennessee, on September 28 and 29, 

2004. At the hearing, both parties called 

witnesses to testify and introduced 

documentary evidence. Following the 

hearing, but before the record was 

closed, the Government introduced into 

evidence the affidavit of its expert 

witness, Mr. Jonathan Robbin. 

Respondent then submitted into 

evidence his own affidavit addressing 

the issues raised in the Robbin affidavit, 

as well as several other exhibits. 

Following the closing of the record, both 

parties submitted post-hearing briefs. 

On October 28, 2005, the ALJ 

submitted her decision recommending 

that Respondent’s registration be 

revoked. Neither party filed exceptions. 

The record was then transmitted to me 

for final agency action. 

Having considered the record as a 

whole, I hereby issue this decision and 

final order. I adopt the ALJ’s findings of 

fact and conclusions of law except as 

expressly noted herein. For the reasons 

set forth below, I concur with the ALJ’s 

recommendation that Respondent’s 

registration be revoked. I further order 

that any pending applications for 

renewal or modification of Respondent’s 

registration be denied. 

Findings 

Respondent is a corporation whose 

shares are owned entirely by Mr. Roy T. 

Young. Respondent is the holder of DEA 

Certificate of Registration, 004395TSY, 

which authorizes it to distribute the List 

I chemicals phenylpropanolamine, 

ephedrine and pseudoephedrine.1

Respondent, which is located in 

Hermitage, Tennessee, sells a variety of 

general merchandise and nonfood items 

such as ball caps, sunglasses, cigarette 

lighters, novelty items and licensed 

athletic wear to predominately gas 

stations and convenience stores in 

eastern and middle Tennessee. Mr. 

Young testified that Respondent ‘‘did a 

couple of million dollars a year by the 

early 2000s.’’ Tr. 233. Mr. Young further 

testified that ephedrine was ‘‘about nine 

or ten percent of my sales in the chain 

stores.’’ Id. at 290. Mr. Young also 

testified that he had decided not to carry 

pseudoephedrine although he did sell it 

‘‘from time to time’’ to certain 

customers. Id. at 240. 

Methamphetamine and the Market for 

List I Chemicals 

While both ephedrine and 

pseudoephedrine have therapeutic 

uses,2 they are also precursor chemicals 

that are regulated by the Controlled 

Substances Act. See 21 U.S.C. 802(34). 

Moreover, these chemicals are easily 

extracted from legal and what typically 

were over-the-counter products 3 and 

used in the illicit manufacture of 

methamphetamine, a schedule II 

controlled substance. See 21 CFR 

1308.12(d). 

Methamphetamine ‘‘is a powerful and 

addictive central nervous system 

stimulant.’’ D & S Sales, 71 FR 37607, 

37608 (2006). The illegal manufacture 

and abuse of methamphetamine pose a 

grave threat to this country. 

Methamphetamine abuse has destroyed 

numerous lives and families and has 

ravaged communities. Moreover, 

because of the toxic nature of the 

chemicals used in producing the drug, 

illicit methamphetamine laboratories 

cause serious environmental harms. 

According to the testimony of DEA 

Special Agent Guy Hargreaves, Staff 

Coordinator for the DEA 

Methamphetamine Program at DEA 

Headquarters, in 1999 there were 101 

explosions and at least 64 fires at 

clandestine labs throughout the United 

States. See Gov. Exh. 26, at 9. Moreover, 

the annual cost to government agencies 

to clean up methamphetamine labs is 

‘‘millions of dollars.’’ Id. at 10.4

The problem of methamphetamine 

abuse is especially serious in Tennessee. 

According to the record, the number of 

law enforcement seizures of clandestine 

laboratories in Tennessee rose from 106 

in 1999 to ‘‘over 700 labs’’ in 2003. See 

ALJ at 8, Tr. at 14. Moreover, according 

to a DEA Special Agent, as of September 

28, 2004 (the date of the hearing), there 


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5As noted in Gregg Brothers Wholesale Co., Inc., 

71 FR 59830 (2006), in 2004, law enforcement 

agencies seized 939 clandestine labs in Tennessee. 

had been close to 700 seizures in 

Tennessee already that year.5 Tr. at 14. 

A DEA Special Agent who serves in 

the Nashville office as a clandestine lab 

enforcement agent testified that, based 

on his observations of products found at 

clandestine lab sites, as well as 

interviews he had conducted with 

various defendants, there was a trend of 

methamphetamine cooks obtaining List 

I chemicals from ‘‘smaller gas stations 

and convenience stores.’’ Id. at 12. 

According to the Special Agent, he had 

been told in the interviews that meth. 

cooks were ‘‘able to buy cases, half 

cases, and such out the back door of’’

convenience stores and gas stations. Id. 

The Special Agent further testified that 

some meth. cooks drive around to 

different stores with four or five 

different addicts who go into several 

stores in different cities and purchase 

sub-threshold quantities of List I 

chemicals. 

The Government submitted into 

evidence the affidavit of Mark J. 

Rubbins, a Diversion Investigator who 

was then assigned as Chief of the 

Domestic Chemical Control Unit, Office 

of Diversion Control, DEA Headquarters. 

According to DI Rubbins, DEA has 

determined that there is both a 

traditional and non-traditional market 

for List I chemical products. See Gov. 

Exh. 44, at 5. The traditional market is 

characterized by a short chain of 

distribution. In this market, 

manufacturers either sell directly to 

large chains of grocery stores (such as 

Giant and Safeway), pharmacies (such 

as Rite Aid and CVS), and other larger 

retailers (such as Wal-Mart), or they sell 

to large wholesalers (such as Bergen 

Brunswig and AmeriSource). See id. at 

5–6. Furthermore, List I chemical 

products sold in this market are 

typically of lower strength and lower 

count sizes such as 30 mg. 

pseudoephedrine tablets in small, 

blister pack sizes of six, twelve, twentyfour and sometimes forty-eight count. 

See id. at 5. 

In contrast, products sold in the nontraditional market pass through multiple 

layers of distribution and are sold by 

such establishments as gas stations, 

small convenience stores, liquor stores, 

headshops, beauty parlors, and video 

stores. See id. at 6. Moreover, the 

products are typically stronger than 

those found in the traditional market 

and include 60 mg. pseudoephedrine 

tablets which are sold in larger package 

sizes such as 60, 100, or 120 count 

bottle sizes. DI Rubbins further stated 

that non-traditional retailers tend to 

knowingly sell large quantities of List I 

chemical products to ‘‘smurfers,’’

individuals who work for 

methamphetamine traffickers and 

attempt to buy out a store’s entire stock 

of List I chemical products by going to 

the store at different times or on 

different days. See id. at 6–7. 

DI Rubbins stated that because of 

increased DEA enforcement efforts 

involving pseudoephedrine products, 

methamphetamine traffickers have 

increasingly gone back to using 

combination ephedrine products. See 

id. at 10. DI Rubbins further stated that 

in 2002, he contacted the major 

manufacturers of combination 

ephedrine/guaifenesin products and 

determined that sales for these products 

amounted to only one-tenth of the 

market for legitimate single-entity 

pseudoephedrine products. See id. 

According to DI Rubbins, the names of 

products that are popular with 

methamphetamine traffickers are 

‘‘MiniThin’’ and ‘‘Mini Twin,’’ which 

each contain 60 mg. pseudoephedrine, 

and ‘‘Max Brand’’ and ‘‘Mini Two 

Way,’’ which are combination 

ephedrine products. See id. at 12. Mr. 

Rubbins further stated that these brands 

‘‘have been disproportionately 

represented in clandestine lab seizures 

around the United States involving 

listed chemical products.’’ Id. at 13. 

The Government also submitted the 

affidavit of John Uncapher, who was 

then assigned as a Staff Coordinator 

with the Domestic Operations Division 

at DEA Headquarters. Mr. Uncapher’s 

staff was responsible for the DEA 

Warning Letter program. See Gov. Exh. 

42, at 3. Under this program, DEA 

collects information regarding List I 

chemicals products that have been 

found at clandestine lab sites and 

identifies the manufacturers of these 

products. See id. The Government 

entered into evidence a list of 35 

warning letters issued to PDK 

Laboratories, the manufacturer of Max 

Brand, a product which Respondent 

distributes. See Gov. Exh. 19. According 

to this exhibit, between January 5, 1999, 

and September 26, 2002, approximately 

1.67 million pseudoephedrine tablets 

and 107,250 combination ephedrine 

tables manufactured by this firm were 

found in numerous seizures of 

clandestine laboratories throughout the 

United States including Tennessee. The 

Government also introduced into 

evidence a list of 17 warning letters 

issued to BDI because their products, 

which Respondent also distributed, 

were found during seizures of 

clandestine laboratories. See Gov. Exh. 

20. 

The Government submitted into 

evidence the declaration of Jonathan 

Robbin, an expert in statistical analysis 

of demographic, economic, geographic 

and survey data. Based on his study of 

the latest available United States 

Economic Census of Retail Trade, Mr. 

Robbin concluded that ‘‘over 97% of all 

sales of non-prescription drug products 

occur in drug stores and pharmacies, 

supermarkets, large discount 

merchandisers and electronic shopping 

and mail order houses.’’ Gov. Exh. 70, 

at 4. Moreover, sales of non-prescription 

drugs by convenience stores (including 

both those that sell and do not sell 

gasoline), ‘‘account for only 2.2% of the 

overall sales of all convenience stores 

that handle the line and only 0.7% of 

the total sales of all convenience 

stores.’’ Id. 

Mr. Robbin further testified that based 

on his study of U.S. Government 

Economic Census Data, information 

obtained from the National Association 

of Convenience Stores, and 

commercially available point of sale 

transaction data, he constructed a model 

of the traditional market for retail sales 

of pseudoephedrine. See id. at 5. 

According to Mr. Robbin, sales of 

pseudoephedrine account for ‘‘only 

about 2.6%’’ of the sales of health and 

beauty care products in convenience 

stores and only ‘‘0.05% of total in-store 

(non-gasoline) sales.’’ Id. 

Mr. Robbin testified that ‘‘the normal 

expected retail sale of pseudoephedrine 

(Hcl) tablets in a convenience store may 

range between $0 and $40 per month, 

with an average of $20.60 per month.’’

Id. at 7. Mr. Robbin also testified that 

‘‘the expected sale of ephedrine (Hcl) 

tablets in a convenience store ranges 

between $0 and $25, with an average of 

$12.58.’’ Id. at 7–8. Mr. Robbin further 

testified that a monthly retail sale of $40 

of ephedrine or $60 of pseudoephedrine 

would ‘‘occur less than one in 1,000 

times in random sampling.’’ Id. 

Moreover, a monthly retail sale of $60 

of ephedrine or $100 in 

pseudoephedrine would ‘‘occur about 

once in a million times in random 

sampling.’’ Id. 

The Investigation of Respondent 

Respondent’s initial registered 

location was 1319 Central Court, 

Hermitage, Tennessee. On July 19, 2001, 

Mr. Young wrote a letter to DEA’s 

Nashville office informing it that 

Respondent had relocated its warehouse 

to 1320 Central Court, Hermitage, 

Tennessee, and requesting that DEA 

issue a registration for the new address. 

See Gov. Exh. 3. According to Mr. 

Young’s testimony, Respondent had 

leased both the 1319 and 1320 locations 


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6The DIs further informed Mr. Young that under 

Federal regulations, records of purchases over 

certain amounts must be maintained at the 

registered location. See Tr. 37–38. The record 

contains an invoice documenting a purchase from 

PDK Laboratories of 720 bottles containing 60 

tablets of 2 way ephedrine, a product that contains 

25 mg. of ephedrine hydrochloride per tablet. See 

Gov. Exh. 6. Respondent’s purchase of this product 

did not, however, exceed the one kilogram 

threshold. See 21 CFR 1310.04(f)(1); Gov. Exh. 23. 

7The audit actually covered the period from July 

1, 2001, through August 7, 2001. See Gov. Exh. 12. 

8There was a factual dispute as to whether 

Respondent informed the DIs as to the existence of 

his computerized records. The ALJ found that 

‘‘whatever computerized records Respondent 

maintained showed only the dollar amount of the 

sale but not the products sold; this latter 

information was shown only on hard copy 

invoices.’’ ALJ at 15; see also Tr. at 252. Because 

the accountability audit was based on the quantity 

and not dollar amount of the products, the dispute 

is immaterial. 

9There is, however, conflicting testimony by Mr. 

Young that when the DIs were through with the 

audit, ‘‘we sat down and had a short meeting out 

front, then a reference was made to a large overage 

in one category’’ and I told the DIs ‘‘you can’t 

honestly be over.’’ Tr. at 253. 

for some period. When Respondent’s 

lease for the 1319 location came up for 

renewal, Mr. Young decided to 

terminate it and vacate the premises as 

he was already leasing the 1320 space 

and had leased another premises (4706 

Lebanon Pike) which he was using for 

an office and retail store. See Tr. 242–

43. Mr. Young did not notify DEA, 

however, until after Respondent moved 

out of its then registered location. Id. at 

244–45. 

Because DEA’s regulations provide 

that a ‘‘request for modification shall be 

handled in the same manner as an 

application for registration,’’ 21 CFR 

1309.61, on August 7, 2001, two DIs 

visited Respondent’s 1320 Central Court 

facility to conduct an investigation. ALJ 

at 15. The DIs inspected the facility and 

obtained from Respondent lists of both 

its customers and suppliers. The DIs 

found that the List I chemical products 

were securely stored in a locked area of 

the warehouse. See id. 

The DIs told Mr. Young that they 

would conduct an accountability audit. 

The DIs conducted an inventory of all 

List I chemical products on hand and 

obtained Mr. Young’s signature on their 

inventory report. Tr. 39–40. The DIs also 

told Mr. Young that they needed to 

know what inventory was on 

Respondent’s delivery trucks. Id. at 40. 

One of the DIs could not recall, 

however, whether Mr. Young had said 

there were List I chemical products on 

the trucks. Id. at 41. The DI later 

testified that Mr. Young had never 

gotten back to them regarding List I 

chemicals that may have been on the 

trucks. Id. at 131. In his testimony, Mr. 

Young confirmed that the DIs had asked 

him about ‘‘the truck inventory’’ and 

whether there were any ‘‘inventories on 

the truck.’’ Id. at 254. 

The DIs then requested the invoices 

necessary to conduct an accountability 

audit. Mr. Young told the DIs that the 

records were not kept at the warehouse 

but were at his office, which was 

located at 4706 Lebanon Pike.6 The DIs 

then went to the office. Id. at 37. 

The DI proceeded to perform a 30 day 

accountability audit 7 of three of the 

products—Ephedrine Plus 60 tablet 

bottles, Max Brand 60 tablet bottles, and 

Nyquil two tablet packets. Because there 

was no beginning inventory, the DIs 

assigned a value of zero for each of the 

products. Id. at 47. The DIs then 

examined both the hard copy purchase 

invoices from Respondent’s suppliers 

and Respondent’s hard copy sales 

records.8 Id. at 51, 147. The audit 

determined that there were overages in 

the amount of 3,131 Ephedrine Plus 

bottles and 600 NyQuil packets. Gov. 

Exh. 12. The audit also found a shortage 

of 26 bottles of Max Brand Ephedrine. 

Id. 

The ALJ found that ‘‘[t]he 

investigators did not contact Mr. Young 

to discuss the audit results’’ and noted 

that ‘‘Mr. Young testified that he was 

not aware of the audit results until three 

years after the August 7, 2001 visit.’’

ALJ at 17.9 The ALJ further found that 

Mr. Young then had his employees go 

back through his records and recalculate 

Respondent’s sales; the employees 

found overages. See id.; see also Tr. 

257–58. 

In October 2001, DEA modified 

Respondent’s registration by changing 

the address of his registered location to 

1320 Central Court. The DI testified that 

he had granted the modification because 

of the financial hardship Mr. Young was 

undergoing in maintaining three 

separate premises. Tr. at 33. 

Approximately a year after the on-site 

inspection, one of the DIs conducted 

verification visits of three of 

Respondent’s customers. ALJ at 18. The 

manager at each location verified that 

the store was a customer of Respondent; 

each of the managers also told the DI 

that they used more than one supplier 

of List I chemicals. See id. At two of the 

stores, the managers told the DI that 

they were attempting to identify 

customers who they believed were 

purchasing List I chemical products for 

illicit use and report them to law 

enforcement authorities. See id. 

On September 19, 2003, Mr. Young 

requested another modification of the 

registration to change both the name on 

the registration and the address of its 

registered location to 4706 Lebanon 

Pike. On December 17, 2003, however, 

the instant Show Cause Order was 

issued. See ALJ at 17. 

On February 20, 2004, two DIs and a 

Special Agent visited Respondent at its 

Lebanon Pike location to deliver a letter 

from Howard Davis, the Diversion 

Program Manager for DEA’s Atlanta 

Field Division. The letter instructed 

Respondent that he could not store 

listed chemicals at his new proposed 

location until DEA approved the 

change. Gov. Exh. 46. The letter further 

explained that DEA would not approve 

any modification until the Order to 

Show Cause was resolved. Id. 

During the visit, Mr. Young told one 

of the DIs that no List I chemicals were 

being stored at the Lebanon Pike 

location. However, during the visit, one 

of the DIs found a display rack 

containing 24 bottles and 5 packets of 

ephedrine products on a shelf in the 

office. ALJ at 17. Because the products 

were at a non-registered location, the DI 

immediately seized them. Id. 

Mr. Young testified that the products 

were at the Lebanon Pike location 

because his son had taken them there to 

photograph them for a brochure to be 

used in marketing them to Respondent’s 

customers. Tr. 277. Mr. Young testified 

that after the pictures were taken the 

products should have been immediately 

returned to the truck. Id. at 278. 

As part of DEA’s investigation, one of 

the DIs obtained from Respondent’s 

suppliers copies of invoices 

documenting its purchases of List I 

chemical products from January 2003 

through July 2004. Tr. at 166–75. 

According to the invoices from one 

supplier, CB Distributors, Respondent 

purchased 5,616 bottles of Rapid Action 

(60 tablet count), 576 bottles of Rapid 

Action (48 tablet count), 10,850 packets 

of Rapid Action (12 tablet count), 3,168 

bottles of Mini Two Way (60 tablet 

count), 576 bottles of Mini Two Way (48 

tablet count), 3,456 packets of Mini Two 

Way (6 tablet count), 15,708 bottles of 

Max Brand 2-Way (60 tablet count), 

17,280 packets of Max Brand 2-Way (6 

tablet count), and 1,584 bottles of Twin 

Tabs (60 tablet count). ALJ at 18. 

The Government also introduced two 

invoices it had received from another of 

Respondent’s suppliers, Sasser 

Distributing. The invoices show that on 

July 27, 2004, Respondent purchased 

288 bottles of ephedrine products (60 

tablet count); the next day, Respondent 

purchased another 144 bottles of Biotek 

Ephedrine (48 tablet count), as well as 

an additional amount of Ephedrine Plus 


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10 During the August 2001 on-site inspection, the 

DIs received a supplier list from Mr. Young. Tr. 56. 

One of the DIs determined that at least two of 

Respondent’s suppliers had received warning 

letters from DEA. ALJ at 18. 

11Mr. Robbin’s affidavit explains in detail his 

methodology, including the figure he used for the 

products’ gross margin, to calculate the implied 

retail sales value of the products. 

packets (6 tablet count). See Gov. Exhs. 

52–53.10

As stated above, the Government 

entered into evidence the affidavit of 

Jonathan Robbin. According to the 

affidavit, DEA provided Mr. Robbin 

with a list of 801 wholesale transactions 

involving combination ephedrine and 

pseudoephedrine products made by 

Respondent to 97 Tennessee 

convenience stores between January 27, 

2003, and November 22, 2004. Gov. Exh. 

70, at 12. The affidavit further stated 

that during this period Respondent sold 

17,271 bottles, each containing 60 

tablets, and 24,520 packages, each 

containing six tablets, of combination 

ephedrine products. See id. The bottles 

held a total of 1,036,260 tablets and the 

packets held a total of 147,120 tablets. 

Id. Respondent also sold to 31 

convenience stores, 1,435 bottles, each 

containing 60 tablets of Max Brand 30 

mg. pseudoephedrine, for a total of 

86,100 tablets of pseudoephedrine 

products. Id. 

Using this data, Mr. Robbin calculated 

each store’s implied average monthly 

retail sales and compared that to the 

normal expected retail sales discussed 

above.11 See id. at 13. According to Mr. 

Robbin, only one of the 97 stores was 

selling near the normal expected sales 

range at 2.8 times expectation. Id. at 15. 

The next lowest store was selling over 

20 times the expected sales range. Id. 

Mr. Robbin explained that in random 

sampling, sales over 20 times 

expectation ‘‘could occur only about 

three times in a billion raised to the fifth 

power.’’ Id. Mr. Robbin further 

explained that ‘‘[t]he probability of an 

index equal to or greater than 20 is so 

small as to be near impossibility.’’ Id. at 

16. Finally, Mr. Robbin found that the 

top 94 stores had indexes over 25, the 

top 54 stores sold ‘‘over 100 times 

expectation,’’ and the top sixteen sold 

‘‘over 300 times expectation.’’ Id. at 16. 

Mr. Robbin explained that ‘‘[s]uch 

indexes are not possible in the normal 

commerce of these goods at ordinary 

convenience stores.’’ Id. According to 

Mr. Robbin, because the average 

convenience store serves 120,000 

shoppers per year, if combination 

ephedrine products were being 

purchased by customers to treat asthma 

(the purpose for which the FDA has 

approved them), three million persons 

would have to shop at the store in a year 

to account for sales 25 times the 

expected amount. Id. Mr. Robbin further 

explained that while it was possible that 

a single customer could purchase a 

store’s entire monthly inventory, this 

amount of product would supply the 

person with enough of the drug to treat 

an asthmatic condition at recommended 

doses for two and one-quarter years. Id. 

Mr. Robbin explained that ‘‘[i]t is 

difficult to imagine * * * what such a 

shopper would do with all of this 

material every month except to resell or 

use it as a precursor chemical in the 

illicit manufacture of 

methamphetamine.’’ Id. at 16–17. Mr. 

Robbin thus concluded that Respondent 

‘‘frequently sells combination ephedrine 

* * * and single ingredient 

pseudoephedrine * * * products to 

these stores in extraordinary excess of 

normal or traditional demand by 

ordinary convenience store shoppers.’’

Id. at 17. 

Mr. Young submitted an affidavit 

challenging the factual basis of Mr. 

Robbin’s findings. According to Mr. 

Young, he supplied records covering 

only the 365 day period from September 

2003 through August 2004. Resp. Exh. 

19, at 1. Mr. Young further stated that 

‘‘the total number of stores serviced 

fluctuate[d] and was not a hard and fast 

97 stores as stated by Mr. Robbin.’’ Id. 

Mr. Young also challenged Mr. 

Robbin’s findings as to the monthly 

expected sales range of combination 

ephedrine and pseudoephedrine 

products in convenience stores. Mr. 

Young asserted that according to the 

March 28, 2005 edition of Convenience 

Store News, ‘‘the average c-store sold 

$5,462 worth of cold and cough 

remedies in 2003.’’ Id. Mr. Young also 

asserted that according to the National 

Association of Convenience Stores State 

of the Industry Report for 2003, ‘‘the 

average c-store sold $2,980 of cough & 

cold remedies in 2003.’’ Id. at 2. Mr. 

Young thus contends that ‘‘[t]hese 

independent studies show average 

monthly sales of $250 to $450 per store 

per month for the c-store industry. This 

amount is 8 to 14 times greater than 

what Robin [sic] reports.’’ Id. Mr. Young 

further asserted that Respondent’s 

average per store sales of combination 

ephedrine products ‘‘is within the 

norms for the sale of these products to 

convenience stores that we have 

experienced in the 14 years that we 

have been in business.’’ Id. at 4. 

In support of his affidavit, Mr. Young 

also submitted into evidence a 

spreadsheet showing its List I chemical 

sales from September 2003 through 

August 2004. See Resp. Exh. 20. 

According to the spreadsheet, 

Respondent sold a total of $68,568.11 of 

List I chemical products to an average 

of 54 stores per month. See id. The 

spreadsheet also indicates that 

Respondent’s average sale per store, per 

month, was $105.81, and calculates that 

the average retail sale per store, per 

month, was $184.00. Id. The 

spreadsheet also indicates that 

Respondent’s sales of traditional 

branded products (such as Advil, Aleve, 

Tylenol, Dayquil and Nyquil that 

contain pseudoephedrine) amounted to 

only $1,507 out of the total of $68,568, 

or approximately two percent of its List 

I chemical product sales. Id. 

Discussion 

Section 304(a) of the Controlled 

Substances Act provides that a 

registration to distribute a List I 

chemical ‘‘may be suspended or revoked 

* * * upon a finding that the registrant 

* * * has committed such acts as 

would render his registration under 

section 823 of this title inconsistent 

with the public interest as determined 

under such section.’’ 21 U.S.C. 

§ 824(a)(4). In making this 

determination, Congress directed that I 

consider the following factors: 

(1) Maintenance by the applicant of 

effective controls against diversion of listed 

chemicals into other than legitimate 

channels; 

(2) compliance by the applicant with 

applicable Federal, State, and local law; 

(3) any prior conviction record of the 

applicant under Federal or State laws relating 

to controlled substances or to chemicals 

controlled under Federal or State law; 

(4) any past experience of the applicant in 

the manufacture and distribution of 

chemicals; and 

(5) such other factors as are relevant to and 

consistent with the public health and safety. 

Id. § 823(h). 

• These factors are considered in the 

disjunctive.’’ Joy’s Ideas, 70 FR 33195, 

33197 (2005). I may rely on any one or 

a combination of factors, and may give 

each factor the weight I deem 

appropriate in determining whether a 

registration should be revoked or an 

application for a modification of a 

registration should be denied. See, e.g., 

David M. Starr, 71 FR 39367, 39368 

(2006); Energy Outlet, 64 FR 14269 

(1999). Moreover, I am ‘‘not required to 

make findings as to all of the factors.’’

Hoxie v. DEA, 419 F.3d 477, 482 (6th 

Cir. 2005); Morall v. DEA, 412 F.3d 165, 

173–74 (D.C. Cir. 2005). My analysis of 

the factors in this case compels the 

conclusion that Respondent’s continued 

registration would be inconsistent with 

the public interest. 


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Factor One—Maintenance of Effective 

Controls Against Diversion 

I acknowledge that Respondent 

provides effective security against the 

theft of listed chemicals. Accurate 

recordkeeping is, however, another 

important control against diversion. See 

21 CFR 1309.71(b)(8). As to this system, 

the record clearly indicates that 

Respondent does not maintain effective 

controls against diversion. 

The accountability audit found that 

two of the products sold by Respondent 

had overages; the other product had a 

shortage. As the ALJ noted, the DIs used 

a zero opening inventory for each 

product because Respondent did not 

have an inventory. Using a zero opening 

inventory will result in an over-count if, 

in fact, a registrant had product on hand 

on the beginning date of the audit 

period. I note, however, that Mr. Young 

testified that he had his employees go 

back through his records and they too 

came up with overages. Tr. 257–58. 

The DIs also found that there was a 

shortage of 26 Max Brand 60 tablet 

bottles. This is especially significant 

because the audit covered only a short 

period of time (approximately five 

weeks). Moreover, if, in fact, 

Respondent had product on hand on the 

beginning date of the audit period, 

assigning an inventory of zero would 

result in an undercount of the shortage. 

I further note the testimony regarding 

whether there was inventory on the 

trucks. The ALJ noted that there was 

‘‘somewhat inconsistent testimony 

about whether some List I chemicals 

were on’’ the trucks. See ALJ at 22. I am 

satisfied, however, that the DIs asked 

Respondent whether there were any List 

I chemicals on the trucks, see Tr. 40 and 

254, and the fact remains that 

Respondent had no readily obtainable 

records showing the amount of 

inventory, if any, that was on the trucks. 

I therefore conclude that Respondent 

does not maintain effective controls 

against diversion. This factor thus 

supports a finding that Respondent’s 

continued registration would be 

inconsistent with the public interest. 

Factor Two—Compliance with 

Applicable Federal, State, and Local 

Laws 

The record here demonstrates that 

Respondent committed several 

violations of Federal law and 

regulations. First, in July 2001, 

Respondent moved its List I chemicals 

from the 1319 Central Court building, 

which was its registered location, to the 

1320 Central Court building, without 

obtaining approval from DEA. This 

action violated 21 U.S.C. § 822(e) and 21 

CFR 1309.23(a). 

The ALJ also found that Respondent 

violated 21 CFR 1310.04(c), by storing 

List I chemical records at its Lebanon 

Pike location, which was not registered. 

See ALJ at 23. The record does not, 

however, support this finding. While 21 

CFR 1310.04(c) requires that records be 

maintained ‘‘at the regulated person’s 

place of business where the transaction 

occurred,’’ id., the provision applies 

only to records which must be 

maintained under 21 CFR 1310.03. The 

only provision of that section which is 

pertinent here is the requirement that a 

regulated person keep a record of ‘‘a 

regulated transaction.’’ Id. § 1310.03(a). 

The regulations establish that the 

threshold for transactions in 

combination ephedrine products 

between wholesale distributors is one 

kilogram. Id. § 1310.04(f)(1)(ii); see also 

Comprehensive Methamphetamine 

Control Act of 1996, Pub. L. No. 104–

237, § 401(f), 110 Stat. 3099, 3110 (1996) 

(adopting one kilogram threshold for 

regulated transactions in combination 

ephedrine products between wholesale 

distributors). 

The record contains only a single 

invoice conceivably documenting a 

regulated transaction between 

Respondent and one of its suppliers, 

PDK Laboratories, which had occurred 

at the time of the August 2001 

inspection. This invoice indicates that 

on July 17, 2001, Respondent purchased 

720 bottles containing 60 combination 

ephedrine tablets of 25 mg. ephedrine 

hydrochloride for a total of 43,200 

tablets. See Gov. Exh. 6. This amount of 

product does not, however, exceed the 

one kilogram threshold because the 

hydrochloride constitutes 

approximately 18 percent of the 

chemical. As the Government’s own 

exhibit demonstrates, the one kilogram 

threshold was equivalent to 48,826 

combination ephedrine hcl tablets each 

containing 25 mg. ephedrine hcl. See 

Gov. Exh. 23. Because Respondent’s 

purchase was more than 5,000 tablets 

under this amount, and there is no other 

evidence indicating that Respondent 

engaged in additional purchases during 

the month, the record does not establish 

that Respondent violated 21 CFR 

1310.04(c). 

The record does, however, contain 

evidence establishing an additional 

violation of DEA regulations. During the 

February 2004 visit, the DIs found a 

display rack containing 24 bottles and 5 

packets of combination ephedrine 

products at Respondent’s Lebanon Pike 

store/office. Because Respondent’s 

Lebanon Pike facility was not a 

registered location, Respondent’s 

storage of the items at this location 

violated 21 U.S.C. § 822(e) and 21 CFR 

1309.23(a). Most remarkably, 

Respondent committed this second 

violation after having been served with 

a Show Cause Order. 

Because Respondent committed 

multiple violations of the CSA’s 

provisions, I conclude that 

Respondent’s record of compliance with 

Federal law supports a finding that its 

continued registration would be 

inconsistent with the public interest. 

Factor Three—The Record of Criminal 

Convictions 

The record contains no evidence that 

Respondent’s owner, or any employee, 

has been convicted of an offense under 

laws related to either controlled 

substances or listed chemicals. I thus 

conclude that this factor supports a 

finding that Respondent’s continued 

registration would not be inconsistent 

with the public interest. 

Factor Four—Past Experience in 

Distributing Listed Chemicals 

It is undisputed that Respondent has 

distributed List I chemical products for 

several years. That experience is, 

however, characterized by several 

violations of the CSA, as well as the 

inability of Respondent to provide an 

accurate accounting of its products. 

Moreover, as described under factor five 

below, there is substantial evidence in 

the record establishing that 

Respondent’s products have been 

diverted. Accordingly, this factor 

supports a finding that Respondent’s 

continued registration would be 

inconsistent with the public interest. 

Factor Five—Other Factors That Are 

Relevant to and Consistent With Public 

Health and Safety 

The record here establishes—as do 

numerous agency precedents—that 

there is a substantial nexus between the 

sale of certain non-traditional List I 

chemical products by non-traditional 

retailers and the diversion of these 

products into the illicit production of 

methamphetamine. See, e.g., John 

Vanags, 71 FR 39365, 39366 (2006); Joey 

Enterprises, 710 FR 76866, 76887 

(2005); TNT Distributors, 70 FR 12729, 

12730 (2005). Indeed, as noted recently 

in TNT Distributors, which also 

involved a Tennessee-based distributor 

of List I chemicals, ‘‘80 to 90 percent of 

ephedrine and pseudoephedrine being 

used [in Tennessee] to manufacture 

methamphetamine was being obtained 

from convenience stores.’’ 70 FR at 

12730. 

Likewise in this case, there is 

undisputed testimony by a DEA Special 


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12While this figure is an average, it is unlikely 

that all stores bought right at the average. Some 

stores bought less, some bought more. 

13 In contrast to the provision pertaining to 

practitioners, the public interest determination 

applicable to List I chemical distributors does not 

limit the Attorney General’s discretion to 

considering only those factors that ‘‘threaten public 

health and safety.’’ Compare 21 U.S.C. § 823(h)(5) 

with id. § 823(f)(5) (‘‘such other factors as are 

relevant to and consistent with public health and 

safety’’). The discussion in the text to the threat 

caused by the diversion of List I chemicals is used 

only to demonstrate the point that a registrant’s 

mens rea is irrelevant. 

14Mr. Young asserts that ‘‘[t]he average per store 

sales of all ephedrine products to our stores is 

within the norms for the sale of these products to 

Agent establishing that Tennessee-based 

methamphetamine cooks were 

purchasing large quantities of List I 

chemicals from smaller stores such as 

gas stations and convenience stores. Tr. 

at 12. Respondent’s List I chemical sales 

were principally made to these types of 

retail establishments. 

Moreover, Respondent’s Exhibit 20, 

which was a compilation of its sales of 

List I chemical products for the period 

September 2003 through August 2004, 

establishes that 98 percent of its sales 

were of non-traditional products 

including those of several 

manufacturers who have received 

warning letters from this agency because 

their products have frequently been 

found during seizures of clandestine 

methamphetamine labs. Respondent’s 

Exhibit 20 further establishes that 

during this period, its average sale per 

store, per month, was $105.81, which 

would result in an average retail sale per 

store, per month, of $184. 

The ALJ found ‘‘persuasive’’ the 

affidavit of Mr. Robbin, the 

Government’s expert witness who 

testified about the market for List I 

chemical products. ALJ at 23. Based on 

this evidence, the ALJ further concluded 

that ‘‘Respondent sold quantities of List 

I chemicals to convenience stores that 

far exceeded what the stores could 

reasonably be expected to sell to 

legitimate consumers.’’ Id. The ALJ also 

rejected Mr. Young’s assertion in his 

post-hearing affidavit challenging Mr. 

Robbin’s testimony as to the normal 

expected sales of combination 

ephedrine and pseudoephedrine 

products in convenience stores. See id. 

According to Mr. Young, the average 

convenience store sold between $250 

and $450 per store, per month, an 

amount that ‘‘is 8 to 14 times greater 

than what Robin [sic] reports.’’ Resp. 

Exh. 19, at 2. 

As the ALJ observed, combination 

ephedrine products cannot be lawfully 

marketed over-the-counter as a cold and 

cough remedy and most of Respondent’s 

sales were of this type of product. See 

ALJ at 23; 21 CFR 341.76. Moreover, 

products containing pseudoephedrine 

are only a subset of over-the-counter 

cold remedies. Respondent has 

produced no evidence establishing the 

percentage of over-the-counter cold 

remedies that include pseudoephedrine. 

I therefore credit Mr. Robbin’s expert 

testimony as to the normal expected 

sales ranges of both ephedrine 

combination and pseudoephedrine 

products in non-traditional retailers. 

Mr. Young also challenged the factual 

basis for Mr. Robbin’s findings that were 

based on data supplied to the latter by 

DEA. According to Mr. Robbin’s 

affidavit, the findings that were specific 

to Respondent were based on ‘‘a list 

supplied to the DEA by T. Young of 801 

wholesale transactions drawn from 

invoices to 97 convenience stores in 

Tennessee,’’ which covered the period 

from January 27, 2003, through 

November 22, 2004. Govt. Exh. 70, at 12. 

Mr. Robbin further stated that the 

‘‘[d]ata given for each transaction 

included invoice date, store name, a 

product description and number of 

units sold.’’ Id. at 13. Mr. Young asserts, 

however, that he supplied DEA with 

‘‘data from September 2003 thru August 

2004,’’ that the data ‘‘was for 365 days, 

not for 665 and the total number of 

stores serviced fluctuate[d] and was not 

a hard and fast 97 stores as stated by Mr. 

Robbin.’’ Resp. Exh. 19, at 1. 

The ALJ did not address this factual 

dispute. Mr. Robbin’s declaration makes 

clear that he did not review the actual 

invoices but rather data provided him 

by the Government. The Government 

did not, however, submit into evidence 

the list of transactions referred to by Mr. 

Robbin or the documentary evidence 

upon which the list was based. 

Moreover, while Mr. Young clearly 

provided data to DEA regarding 

Respondent’s sales, see Resp. Exh. 19, at 

1, the Government did not elicit any 

testimonial evidence from a witness 

with personal knowledge of how the list 

was obtained that establishes the scope 

of the data contained therein and refutes 

Respondent’s contention. Accordingly, 

while I have credited Mr. Robbin’s 

testimony regarding the expected sales 

ranges for combination ephedrine 

products and pseudoephedrine in nontraditional retailers, I do not adopt his 

findings that were based on 

Respondent’s sales. 

Respondent’s own evidence 

nonetheless demonstrates that it sold 

List I chemical products to nontraditional retailers in quantities that far 

exceeded legitimate demand and thus 

supports a finding that its products were 

diverted. During the period of 

September 2003 through August 2004, 

Respondent sold at wholesale prices an 

average of $ 105.81 to each store, each 

month. See Resp. Exh. 20, at 1. By 

Respondent’s calculation, these List I 

chemical products produced an average 

retail sale of $184 per store, per month. 

See id.12

Mr. Robbin found as a general matter 

that the expected retail sales range of 

ephedrine (Hcl) in a convenience store 

is ‘‘between $0 and $25, with an average 

of $12.58.’’ Govt. Exh. 70 at 8. Mr. 

Robbin further found that a monthly 

retail sale of ‘‘$60 of ephedrine (Hcl) 

tablets would be expected to occur 

about once in a million times in random 

sampling.’’ Id. By Respondent’s own 

calculation, its customers’ average 

monthly retail sale of ephedrine 

products was several times this amount. 

Moreover, this average was based on 54 

stores over a twelve month period. It is 

thus even more improbable (than a one 

in a million probability) that these sales 

were to meet legitimate consumer 

demand for these products. I therefore 

conclude that a preponderance of the 

evidence establishes that a substantial 

portion of Respondent’s products were 

diverted. See D & S Sales, 71 FR at 

37611 (finding diversion occurred 

‘‘[g]iven the near impossibility that 

* * * sales were the result of legitimate 

demand’’); Joy’s Ideas, 70 FR at 33198 

(finding diversion occurred in the 

absence of ‘‘a plausible explanation in 

the record for this deviation from the 

expected norm’’). 

That Respondent may have lacked 

any intent to divert or to sell to 

customers who were diverting to the 

illicit manufacture of methamphetamine 

(See Resp. Br. 8) is irrelevant. ‘‘In 

determining the public interest,’’

Congress granted the Attorney General 

broad discretion to consider any other 

factor that is ‘‘relevant to and consistent 

with the public health and safety.’’ 21 

U.S.C. § 823(h)(5). The statutory text 

imposes no requirement that the 

Government prove that a Registrant has 

acted with any particular mens rea. 

Indeed, the diversion of List I chemicals 

into the illicit manufacture of 

methamphetamine poses the same 

threat to public health and safety 13

whether a registrant sells the products 

knowing they will be diverted, sells 

them with a reckless disregard for the 

diversion, See D & S Sales, 71 FR at 

37610–12, or sells them being totally 

unaware that the products were being 

diverted. Cf. Joy’s Ideas, 70 FR at 33198 

(revoking registration notwithstanding 

that distributor was ‘‘an unknowing and 

unintentional contributor to [the] 

methamphetamine problem.’’).14


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convenience stores that [his firm has] experienced 

in the 14 years that we have been in business,’’ and 

that these figures predate the methamphetamine 

problem. Resp. Ex. 19. at 4. The ALJ did not, 

however, credit this testimony. Moreover, 

Respondent did not produce any documentary 

evidence establishing its sales levels prior to the 

emergence of the methamphetamine epidemic in 

Tennessee. Thus, to the extent this testimony was 

offered to show that Respondent’s more recent sales 

were consistent with the traditional and legitimate 

demand for List I chemical products and therefore 

rebut a finding that diversion occurred, I decline to 

credit it. To the extent the testimony was offered 

to show that Respondent did not intend that it 

products be diverted, it is irrelevant. 

Respondent points to the testimony of 

the DI who conducted verification visits 

of three of Respondent’s customers. 

According to Respondent, this 

establishes that ‘‘respondent’s 

customers conscientiously keep[] track 

of the materials sold and report[ ] any 

excess sales to local police.’’ Resp. Br. 

at 6. The record establishes, however, 

that the verification visits involved only 

a small fraction of Respondent’s 

customers and thus this testimony does 

not refute the finding that its products 

were diverted. 

Respondent further asserts that 

following Tennessee’s enactment of the 

Meth-Free Tennessee Act of 2005, as 

well as new laws in Georgia and 

Kentucky, revoking his registration 

would be ‘‘an arbitrary overreaching 

act’’ because the new laws restrict the 

products that can be sold by nontraditional retailers to those in gel-cap 

or liquid form and he is selling only 

these products. Resp. Br. 7. DEA is 

already aware, however, of several 

studies showing that methamphetamine 

can be produced from List I chemicals 

sold as liquid-filled gel caps and 

liquids. See Drug Enforcement 

Administration, Microgram Bulletin 96–

97,102 (June 2005) (discussing studies 

conducted by Washington State Patrol 

Crime Laboratory and McNeil Consumer 

and Specialty Pharmaceuticals). 

Moreover, experience has taught DEA 

that in the aftermath of every major 

piece of legislation addressing the illicit 

manufacture of methamphetamine, 

traffickers have quickly found ways to 

circumvent the restrictions. 

Moreover, even assuming that 

Respondent will fully comply with the 

Tennessee and Kentucky laws, the 

Georgia statute would apparently not 

prohibit Respondent from selling 

combination ephedrine products to nontraditional retailers. See Georgia Code 

§ 16–13–30.3 (allowing convenience 

stores to sell ephedrine products). 

Respondent would also be able to 

distribute products to non-traditional 

retailers in other States which have not 

imposed similar restrictions. Therefore, 

I conclude that factor five supports a 

finding that Respondent’s continued 

registration would be inconsistent with 

the public interest. 

In sum, Respondent has committed 

several violations of the CSA. See 21 

U.S.C. § 823(h)(2). Moreover, 

Respondent has no effective means of 

accounting for List I chemical products. 

Id. § 823(h)(1). Finally, the record 

establishes that Respondent sold large 

amounts of non-traditional products 

into the non-traditional or ‘‘gray 

market,’’ a market which DEA has 

repeatedly found to be a substantial 

source for diversion, and the statistical 

improbability that these sales were to 

meet legitimate consumer demand 

supports a finding that the products 

were diverted into the illicit 

manufacture of methamphetamine. Id. 

§ 823(h)(5). See also Joy’s Ideas, 70 FR 

at 33199; Branex, Inc., 69 FR 8682, 8693 

(2004); Xtreme Enterprises, Inc., 67 FR 

76195, 76197 (2002). Thus, it is clear 

that continuing Respondent’s 

registration would be inconsistent with 

the public interest. 

Order 

Accordingly, pursuant to the 

authority vested in me by 21 U.S.C. 

§ 823(h) & § 824(a), as well as 28 CFR 

0.100(b) & 0.104, I hereby order that 

DEA Certificate of Registration, 

004395TSY, issued to T. Young 

Associates, Inc., be, and it hereby is, 

revoked. I further order that any 

pending applications for renewal or 

modification of such registration be, and 

they hereby are, denied. This order is 

effective November 13, 2006. 

Dated: September 14, 2006. 

Michele M. Leonhart, 

Deputy Administrator. 

[FR Doc. 06–8193 Filed 10–12–06; 8:45 am] 

BILLING CODE 4410–09–P 

LEGAL SERVICES CORPORATION 

Notice of Intent To Award—Grant 

Awards for the Provision of Civil Legal 

Services to Eligible Low-Income 

Clients Beginning January 1, 2007 

AGENCY: Legal Services Corporation. 

ACTION: Announcement of intention to 

make FY 2007 Competitive Grant 

Awards. 

SUMMARY: The Legal Services 

Corporation (LSC) hereby announces its 

intention to award grants and contracts 

to provide economical and effective 

delivery of high quality civil legal 

services to eligible low-income clients, 

beginning January 1, 2007. 

DATES: All comments and 

recommendations must be received on 

or before the close of business on 

November 13, 2006. 

ADDRESSES: Legal Services 

Corporation—Competitive Grants, Legal 

Services Corporation; 3333 K Street, 

NW., Third Floor; Washington, DC 

20007. 

FOR FURTHER INFORMATION CONTACT: 

Reginald Haley, Office of Program 

Performance, at (202) 295–1545, or 

haleyr@lsc.gov. 

SUPPLEMENTARY INFORMATION: Pursuant 

to LSC’s announcement of funding 

availability on April 17, 2006 (71 FR 

19758), and Grant Renewal applications 

due on June 15, 2006, LSC intends to 

award funds to the following 

organizations to provide civil legal 

services in the indicated service areas. 

Amounts are subject to change. 

Service area Applicant name Grant amount 

Alabama 

AL–4 ......................................... Legal Services Alabama, Inc ....................................................................................................... $5,775,139 

MAL .......................................... Texas RioGrande Legal Aid, Inc .................................................................................................. 29,577 

Alaska 

AK–1 ......................................... Alaska Legal Services Corporation .............................................................................................. 668,572 

NAK–1 ...................................... Alaska Legal Services Corporation .............................................................................................. 487,216 


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